Effective: 29 August 2023
Personal Data means any data relating to an individual who can be identified, directly or indirectly, based on that data. This may include data such as names, contact details, (online) identification data, online identifiers or other characteristics specific to that individual.
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Additional Notices
You are not legally required to provide us with any Personal Data but without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services.
If you wish to contact us in relation to questions regarding your Personal Data, please contact us via email at firstname.lastname@example.org or by completing the webform provided at: https://dellalegal.com/data-subject-request-portal/ or by mail at 11 avenue Michel Ricard – 92270 BOIS COLOMBES – FRANCE, for the attention of: Legal/Privacy Department.
- Data Collection
The type of Personal Data we collect depends on your relationship with us and the Services we deliver to you.
When you visit, interact with or use our Site or Platform, we may collect or generate certain Personal Data about you. We collect or generate such Personal Data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Personal Data may include:
- Data that you provide by filling in forms on our Site, providing details by registration or other means at a marketing event, or when setting up administrator accounts in our product or services.
- Data that you provide us to use the Platform including email addresses and phone numbers.
- Data you provide us through inquiries and/or feedback.
- Internet Protocol (IP) address, operating system and web browser used.
- Data when you report a problem with our Site or Services.
- Record of correspondence with Wolters Kluwer.
- Usage data, such as, behavioral data about how you navigate within our Services and which elements of our Services you use the most. Other data shared by you through our website and other products including, but not limited to, traffic data, location data and other communication data, and the resources that you access.
- Any other data shared by you through our websites, and other products and services.
We may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from business partners or Services Providers, and through the use of tools and channels commonly used to connect between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
If you are under 13 years of age, please do not use or access the Services. Wolters Kluwer does not knowingly collect or maintain Personal Data (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years of age. If Wolters Kluwer learns that Personal Data of persons under 13 has been collected on or through the Services, we will take appropriate steps to delete this data.
- Data Uses
We use Personal Data as necessary for the performance of our Site, Platform and Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and sales offerings, understanding how our Site, Platform and Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing visitor of our Site, our customers, ourselves and our Services.
We do not sell your Personal Data for the intents and purposes of the California Consumer Privacy Act (CCPA).
Lawfulness of the processing is one of the main principles relating to the processing of your Personal Data – we apply the following legal processing grounds:
- Processing is necessary for the performance of a contract, or in order to take steps prior to entering into a contract;
- processing is necessary for the purposes of our legitimate interests – for example, to improve the quality of our products and Services;
- processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws;
- with your given consent.
Specifically, we may use Personal Data for the following purposes:
- To authenticate the identity of our customers, and to allow them access to our Platform and Services;
- To facilitate, operate, and provide our Services;
- To further develop, customize and improve the Services and general user experience, based on common or personal preferences, experiences and difficulties;
- To provide with assistance and support;
- To manage and deliver advertisements more effectively, including contextual, behavioral, and interests-based advertising based on activity, preferences or other data available to us or to our business partners, including for retargeting purposes;
- To create audience-related insights for optimizing ad performance;
- To contact you with general or personalized messages and communications;
- To facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
3. Data Location and Retention
Data Location: Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (as defined below) in the UK, France and other jurisdictions, including the European Union, as necessary for the proper delivery of our Services, or as may be required by law.
Wolters Kluwer may be required to transfer Personal Data to countries other than the country in which the data originated. Any such transfers shall be done in compliance with the applicable data protection laws.
Data Retention: Your Personal Data will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the data is collected, in accordance with our data retention policies and the applicable data protection laws. When we no longer need your Personal Data, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.
- Data Sharing
To be able to provide you the best possible Services and further our business operations, we may share certain data internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your Personal Data externally. Parties we might share data with include:
- other Wolters Kluwer affiliates or subsidiaries, e.g. for customer data management or providing underpinning technology to support the Services we are delivering;
- our Service Providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
- our business partners, to the extent you have purchased or expressed interest in a product or service of such a business partner, interacted with them or otherwise authorized the sharing of your Personal Data with such a business partner;
- subscribing, accrediting or professional organizations, e.g. for providing utilization data to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
- organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
- other parties, e.g. as needed for external audits, compliance, risk management, corporate development and/or corporate governance related matters; or
- governmental authorities and regulators, as required under the applicable law.
We may engage selected third party companies and individuals to perform services complementary to our own, namely – hosting, data analytics, consulting, development, support, marketing and advertising, data and cyber security, payment processing, user engagement, e-mail distribution and monitoring, text messaging and session recording; as well as our business, legal and financial advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
We use the Service Providers listed at https://dellalegal.com/subprocessors/ as sub-processors as part of the services provided to our customers.
Whenever we share Personal Data internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses. As required under the applicable law, third parties are required to use appropriate safeguards to protect Personal Data, and they can only access the Personal Data that is necessary for performing their specific tasks.
- Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
A cookie is a small text file that is placed, for example, to collect data about activity on our Site and Platform. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by visitors of our Site.
- Data Security
In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
- Data Subject Rights
As a global organization, we operate in different jurisdictions which grant individuals different levels of protection in relation to the processing of Personal Data. We will honor your rights under the applicable law. To the extent provided under your local data protection laws, including the European data protection laws as applicable, your rights may include the following:
- Right of access (‘an overview of your Personal Data’): the right to get an overview of your Personal Data that we process.
- Right to rectification (‘correct your Personal Data’): if your Personal Data is inaccurate or incomplete, the right to ask us to rectify or complete your Personal Data.
- Right to erasure (‘right to be forgotten’): the right to request that we delete your Personal Data to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract. In some cases, your Personal Data is necessary in order to provide the Services and if you do not provide such data to us then you may be precluded from accessing and using the Services or using certain Services features.
- Right to data portability (‘transfer your Personal Data’): the right to ask us to transfer your Personal Data directly to you. This applies to certain Personal Data if processed by automated means and with your consent, or based on a contract you have with us. On your request, and where technically feasible, we will transfer your Personal Data to another party of your choice.
- Right to restrict processing: the right to request that we restrict or stop the processing of your Personal Data held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
- Right to object: the right to object to the processing of your Personal Data. The reasons for an objection should relate to your particular situation, and be related to processing based on the legitimate interest condition. We will then no longer process the Personal Data, unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object; for instance, in the context of direct marketing activities.
- Withdrawal of Consent: the right to withdraw your consent to the processing of your Personal Data at any time; for instance, after you consented to us keeping you informed about our Services, you have the right to withdraw this consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing of your personal data prior to the withdrawal.
To exercise your rights (if applicable) and/or for any other questions about the handling of your Personal Data, please contact us via email at email@example.com or by completing the webform provided at: https://dellalegal.com/data-subject-request-portal/ or by mail at 11 avenue Michel Ricard – 92270 BOIS COLOMBES – FRANCE, for the attention of: Legal/Privacy Department.
If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your local Data Protection Authority.
- Additional Notices
Questions, Concerns or Complaints: If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact Wolters Kluwer’s at firstname.lastname@example.org.
Wolters Kluwer may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please contact us via email at email@example.com by mail at 11 avenue Michel Ricard – 92270 BOIS COLOMBES – FRANCE, for the attention of: Legal/Privacy Department.
If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.